Australian & Canadian Sustainable Forest Management Standards A Comparative Analysis of AS 4708 (Int)-2003 and CAN/CSA Z809-02

Transcription

1 Sustainable Forest Management Australian & Canadian Sustainable Forest Management Standards A Comparative Analysis of AS 4708 (Int)-2003 and CAN/CSA Z Project No. PN

2 2004 Forest & Wood Products Research and Development Corporation All rights reserved. Publication: Australian & Canadian Sustainable Forest Management Standards - A Comparative Analysis of AS 4708 (Int)-2003 and CAN/CSA Z The Forest and Wood products Research and Development Corporation ("FWPRDC") makes no warranties or assurances with respect to this publication including merchantability, fitness for purpose or otherwise. FWPRDC and all persons associated with it exclude all liability (including liability for negligence) in relation to any opinion, advice or information contained in this publication or for any consequences arising from the use of such opinion, advice or information. This work is copyright and protected under the Copyright Act 1968 (Cth). All material except the FWPRDC logo may be reproduced in whole or in part, provided that it is not sold or used for commercial benefit and its source (Forest and Wood Products Research and Development Corporation) is acknowledged. Reproduction or copying for other purposes, which is strictly reserved only for the owner or licensee of copyright under the Copyright Act, is prohibited without the prior written consent of the Forest and Wood Products Research and Development Corporation. Project no: PN Researchers: D. Neate Canadian Standards Association darryl.neate@csa.ca Forest & Wood Products Research & Development Corporation PO Box 69, World Trade Centre, Victoria 8005 Phone: (03) Fax: (03) info@fwprdc.org,au Web:

3 Australian & Canadian Sustainable Forest Management Standards A Comparative Analysis of AS 4708 (Int)-2003 and CAN/CSA Z Prepared for the Forest & Wood Products Research & Development Corporation by D. Neate The FWPRDC is jointly funded by the Australian forest and wood products industry and the Australian Government.

4 A Comparative Analysis of AS 4708 and CAN/CSA Z Table of Contents 1. Executive Summary 1 Requirements of the Standards...1 Standards Development Process Introduction 5 Scope...5 Report Structure...5 Methodology System Requirements 7 Similarities...7 Differences...8 AFS and CSA Comparative Matrix of System Requirements Public Participation Requirements 17 Similarities Differences AFS and CSA Comparative Matrix of Public Participation Requirements SFM Criteria-Based Performance Requirements 22 Similarities Differences AFS and CSA Comparative Matrix of SFM Criteria-Based Performance Requirements Aboriginal Requirements 33 Similarities AFS and CSA Comparative Matrix of Aboriginal Requirements Standards Development 36 Standards Development Framework Canadian Standards Association Standards Council of Canada Standards Development Process Canada s National SFM Standard, CAN/CSA Z Multi-Stakeholder Technical Committee Composition Public Consultation ENGO Participation Aboriginal Participation CAN/CSA Z809 & AS 4708 (Int) - Summary Annex 1- CAN/CSA-Z Normative Requirements 41 Annex 2 - AS 4708 (Int) Normative Requirements 49 August 26, 2004 i

5 Executive Summary 1. Executive Summary This report includes a comparative analysis of the requirements of the Australian Forestry Standard, AS 4708 (Int)-2003 [AS 4708], and the CSA s Sustainable Forest Management Standard, CAN/CSA Z It highlights the overarching similarities in these standards, as well as areas where they differ. This report also highlights the standards development process used for CAN/CSA Z and specifically issues related to a balanced technical committee including ENGO and Aboriginal representation. There are many fundamental similarities between the Australian Forestry Standard, AS 4708 (AFS) and Canada s National Sustainable Forest Management Standard, CAN/CSA-Z (CSA) including: the incorporation of management system elements that are based on the internationally recognized ISO Environmental Management System Standard; requirements for meaningful public participation in the development of the forest management plan; requirements to address sustainable forest management (SFM) criteria that are consistent with Montreal Process criteria, which are internationally recognized and inter-governmentally developed SFM criteria; respect for Aboriginal rights, traditional knowledge and values; the use of accredited standards development organizations to develop the standard through a balanced technical (reference) committee and in conformance with protocols and procedures set out by their respective national standards systems; efforts made at encouraging brand name ENGOs to become members of their technical committees; and efforts made at encouraging Aboriginals to become members of their technical committees. Requirements of the Standards There are four key requirement areas identified that the AFS and CSA forest management certification standards address: management system requirements; public participation requirements; SFM criteriabased performance requirements; and aboriginal engagement requirements. Management System Similarities Both the AFS and CSA standards have a systems component to their requirements that are consistent with ISO Both standards require that the applicant: Implements a management system Defines a policy Establishes a defined forest area Develops a forest management plan Complies with relevant legislation Defines roles and responsibilities Has operational procedures in place to meet the forest management requirements of the standards Establishes and maintains communications procedures Has emergency response plans/procedures in place Ensures staff and contractors have the skills required to achieve the forest management objectives/requirements Has document control procedures in place August 26,

6 Executive Summary Has procedures to monitor operations to demonstrate progress towards the requirements of the standard Has procedures to allow for remedial and corrective action Conducts audits to determine conformance with the requirements of the standard Conducts management reviews to facilitate continual improvement While the AFS does include comprehensive system requirements, the CSA has more extensive and detailed system requirements with a higher level of conformance with ISO The Introduction to the AFS states, The Australian Forestry Standard may be used either by itself or in conjunction with AS: NSZ ISO 14001: 1996 Environmental Management Systems Specifications with guidance for use. (AFS, page 7) This guidance therefore recognizes the benefits and compatibility of ISO implementation, but the AFS only requires key EMS elements to ensure that smaller companies that do not seek ISO will benefit from some of its key requirements. In the Canadian context, the vast majority of companies which have achieved certification to CAN/CSA- Z809 have already achieved certification to IS , which facilitates the transition from the ISO EMS foundation to the forestry-specific CSA SFM Standard. Public Participation Similarities Both the AFS and CSA standards are similar in that they offer meaningful opportunities for public participation in the development of the forest management plan. Both the AFS and CSA standards require that the applicant: Provide for public participation Contact relevant stakeholders (AFS) / a broad range of interested parties (CSA) affected by or with an interest in the management of the defined forest area. Facilitate meaningful participation in the development of the SFM plan Demonstrate how views/inputs were considered Make a summary of the plan available to stakeholders (AFS) / make the plan publicly available (CSA) The AFS and CSA differ in that the CSA relies on the establishment of an on-gong public participation process to identify and select values, objectives, indicators and targets for each of the CSA SFM elements, as well as any other elements of relevance to the defined forest area, whereas, the AFS provides more specificity at the outset to its SFM criteria. This difference in approach demonstrates that standards can promote SFM in ways that best address the national / regional / local operating context. The non-normative Introduction to the CSA Standard states, Because Canadian forests are primarily publicly owned, it is vital that a Canadian forest certification standard involve the public extensively in the forest management planning process. Certifications to the CSA Standard to date have been on the public lands in Canada, which is not surprising given its rigorous public participation requirements. However, there is nothing that precludes the application of the CSA Standard on private lands, other than the practical reality that most private landowners would find the CSA s public participation requirements out of context in a private land scenario. Given that the AFS Standard was intended for and is being applied on both public and private tenures, it is understandable that the public participation requirements of that standard are not as comprehensive as the CSA s, and instead more specific SFM criteria are required at the outset. SFM Criteria-Based Performance Similarities Both the AFS and CSA standards found their SFM criteria-based performance requirements on criteria that are consistent with the Montreal Process criteria, which are internationally recognized and intergovernmentally developed SFM criteria. Both standards require the applicant to: Maintain / conserve biological diversity August 26,

7 Executive Summary Identify the significance of biological diversity values (AFS) / sites of special biological significance (CSA) Maintain the productive capacity of forests (AFS) / the ecosystem condition and productivity (CSA) Protect / maintain soil and water resources Maintain forest contributions to global ecological cycles, including carbon uptake Recognize the rights and values of Indigenous / Aboriginal peoples Maintain (AFS) / sustain (CSA) forest benefits Provide for the health and safety of workers Despite these similarities, the AFS prescribes a higher degree of specificity and detail in its SFM criteriabased requirements than the CSA standard. However, the 17 CSA SFM elements are in turn interpreted further into specific performance requirements at the local DFA level through a public participation process which results in values, objectives, indicators, and targets being set for each of the 17 CSA SFM elements, and any other elements of relevance to the DFA. Aboriginal Engagement Similarities Both the AFS and CSA standards are similar in that they: Recognize the rights of Indigenous / Aboriginal peoples Protect Indigenous heritage values (AFS) / respect traditional Aboriginal forest values and knowledge (CSA) The AFS and CSA standards share a high degree of conformance in the system, public participation, and SFM criteria-based performance requirements, as well as in their respect and recognition of Aboriginal rights and values. These standards also share some similarities in terms of the processes used to develop them. In summary, there is a high level of conformance across the two Standards in all key requirements areas and where differences do exist, they are often an expression of different operating contexts and/or tenure types. August 26,

8 Executive Summary Standards Development Process The AFS & CSA standards were developed by an accredited standards development organization (SDO). The AFS and CSA standards are quite unique in that they share a leadership position in terms of operating within their respective national standards system institutional framework and thereby fully respecting the procedures and guidelines set out by their national standards bodies. Indeed, the vast majority of forest certification standards developed around the world have been developed outside national standards systems. The AFS & CSA standards were developed by balanced technical (reference) committees (TRC/TC), which followed SDO normal operating procedures for inviting a wide-variety of interested parties to become members of their respective TRC/TCs. The SDOs of the AFS and CSA standards provided ample opportunities for public consultation and input into the development of their standards. The SDOs of the AFS and CSA standards made special efforts to engage large brand name environmental non-governmental organizations (ENGO) on their respective TRC/TCs. In the case of the AFS and CSA efforts were made to invite ENGOs including The World Wide Fund for Nature to join their TRC/TCs. Despite the invitations made, WWF does not sit on either the AFS or the CSA TRC/TC. The CSA SFM TC has enjoyed longstanding conservation representation through Wildlife Habitat Canada, Ontario Federation of Anglers and Hunters, as well as the Canadian Wildlife Federation. In 2004, NatureServe Canada, joined the CSA SFM TC. NatureServe is known for its network of conservation data centres across N. America, and NatureServe s expertise are currently being used as a data resource for SFI certification initiatives. The AFS TRC has an independent environmental scientist sitting on its TRC. Moreover, there are now two nominations from environmental interests in Australia to the AFS TRC, hence it is expected that there will be new independent environmental perspectives within the AFS TRC in the near future. The SDOs of the AFS and CSA standards made special efforts to engage Aboriginal representation on their respective TRC/TCs. CSA had benefited from the National Aboriginal Forestry Association s (NAFA) representation on the CSA SFM TC from the outset of the original CSA Standard development process in the early 1990s. NAFA remained on the CSA SFM TC throughout the 90s and throughout the revision process, however, in April 2002, just days prior to the ballot vote on the revised CSA Standard, NAFA withdrew its membership on the CSA SFM TC. The CSA SFM TC keeps an open door to NAFA involvement and in their absence has secured a new member who has long-standing participation as an Aboriginal representative in a CSA public advisory group that provides on-going decision-making and input into a company certified to CAN/CSA-Z809. In the case of the AFS, proponents attempted to engage two national indigenous organizations associated with forestry issues without luck prior to approaching and securing a Commissioner of the Aboriginal and Torres Strait Islander Commission (ATSIC) as a representative. The Commissioner, from Tasmania, had forest management as one of his specific areas of responsibility under ATSIC. August 26,

9 Introduction 2. Introduction This report was commissioned by the Australian Forest and Wood Products Research and Development Corporation as a comparative assessment of the system and performance requirements of the Australian Forestry Standard (AS 4708) and Canada s National Sustainable Forest Management Standard (CAN/CSA Z809-02). Scope Standards Requirements This report includes a comparative analysis of the requirements of AS 4708 and CAN/CSA Z809-02, i.e. the normative elements of identified key requirements for forest management standards which can provide a credible basis for forest certification. It highlights the overarching similarities in these standards, as well as areas where they differ. The guidance or informative material in these standards generally did not form part of the analysis, nor did any of the AFS Supplements, as those too are considered guidance. However, in areas where guidance material is referenced, it is explicitly categorized as such. Standards Development This report also highlights the standards development process used for CAN/CSA Z and specifically issues related to a balanced technical committee including ENGO and Aboriginal representation. The scope of work did not cover other program elements, such as certification/registration requirements, chain-of-custody requirements, and label use requirements. Report Structure This report is structured as follows: Section 1 - Executive Summary Section 2 - Introduction Section 3 - System Requirements (comparative matrix) Section 4 - Public Participation Requirements (comparative matrix) Section 5 - SFM Criteria-Based Performance Requirements (comparative matrix) Section 6 - Aboriginal Requirements (comparative matrix) Section 7 - Standards Development Annex 1 - CAN/CSA Z Normative Requirements Annex 2 - AS 4708 (Int) Normative Requirements Section 1 provides an Executive Summary highlighting the report s key findings. Each of the sections 3, 4, 5, and 6 of this report commence with a summary of similarities and differences followed by comparative matrices of the normative requirements of the two standards. While the matrices reflect requirements of the standards, in a few instances notes are included in italics. Annex 1 and 2 represent a comprehensive summary of only the requirements found in the two standards under review. Methodology In this report, AS 4708 and CAN/CSA Z are organized into four main themes: system requirements; public participation requirements; performance requirements; and aboriginal requirements. August 26,

10 Introduction The following documents were reviewed to gain an understanding of the rigour used in developing, maintaining, assessing, and continually improving the Australian Forestry Standard and the Australian Forest Certification Scheme: Australian Documents AS 4708: The Australian Forestry Standard AS 4707: The Chain of Custody Standard JAZ-ANZ Australian Forestry Standard Certification Program JAZ-ANZ Product Certification Program including the Chain of Custody Scheme Rules Benchmarking The Australian Forestry Standard by Indufor Oy Supplement to Benchmarking The Australian Forestry Standard by AFS Limited The Australian Forestry Standard Record of Process AFS Group Certification Project The requirements of both standards are publicly availably on the Internet. In addition, the consultant s general knowledge obtained as a member of the CSA SFM Technical Committee since 1994 was integral to the writing of this report. August 26,

11 System Requirements 3. System Requirements Similarities Both the AFS and CSA standards have a systems component to their requirements that are consistent with ISO AFS Section 4, Forest Management Requirements reads: The requirements of the Australian Forestry Standard are derived from certain elements of the International Organisation for Standardisation (ISO) environmental management system (EMS) Standard AS:NZS ISO 14001:1996 The Introduction to the AFS states, The Australian Forestry Standard may be used either by itself or in conjunction with AS: NSZ ISO 14001: 1996 Environmental Management Systems Specifications with guidance for use. (AFS, page 7) This guidance therefore recognizes the benefits and compatibility of ISO implementation, but the AFS only requires key EMS elements to ensure that smaller companies that do not seek ISO will benefit from some of its key requirements. CSA, Section 0. Introduction, Sub-Section 0.5 Consistency with ISO reads: This Standard is consistent with the internationally recognized ISO environmental management system Standard. It is essential to have a management system that can assure the fulfillment of all the CSA SFM requirements. A management system is the vehicle ensuring that both the public participation and performance requirements are fulfilled in a systematic and predictable manner that guarantees continual improvement in the forest. This Standard includes the SFM continuum of Establishing a Policy Planning Implementation and Operation Checking and Corrective Action Management Review. In the Canadian context, the vast majority of companies which have achieved certification to CAN/CSA-Z809 have already achieved certification to IS , which facilitates the transition from the ISO EMS foundation to the forestry-specific CSA SFM Standard. Both the AFS and CSA standards require that the applicant: Implements a management system Defines a policy Establishes a defined forest area Develops a forest management plan Complies with relevant legislation Defines roles and responsibilities Has operational procedures in place to meet the forest management requirements of the standards Establishes and maintains communications procedures Has emergency response plans/procedures in place Ensures staff and contractors have the skills required to achieve the forest management objectives/requirements Has document control procedures in place Has procedures to monitor operations to demonstrate progress towards the requirements of the standard Has procedures to allow for remedial and corrective action August 26,

12 System Requirements Conducts audits to determine conformance with the requirements of the standard Conducts management reviews to facilitate continual improvement. Differences The comparative analysis of the system requirements in the matrix below demonstrates the degree to which the AFS and CSA standards share system similarities. While the AFS does include comprehensive system requirements, the CSA has more extensive and detailed system requirements with a higher level of conformance with ISO Areas where CSA is more rigorous follow: Points of Comparison: System High Level System Requirements Implementation responsibilities and resources Operating procedures Communication, and specifically with regards to the CSA requirement to make publicly available: o the SFM Plan o an annual report on the applicant s performance in meeting and maintaining the SFM requirements o the results of independent certification and surveillance audit reports. (Note: the AFS does require, under clause 4.2, that a summary of the plan and reports on implementation be made available to stakeholders) Training and awareness Documentation Internal audits and management reviews (required annually in CSA, periodically in AFS) AFS and CSA Comparative Matrix of System Requirements AS 4708 (AFS) Section 4.1, incl. Criterion 1 on Systems Criterion 1 Forest management shall be undertaken in a systematic manner that addresses the range of forest values The forest manager shall implement the management system to meet the forest management performance requirements CAN/CSA Z (CSA) Section 7. SFM System Requirements: 7. SFM System Requirements: The Continual Improvement Loop (CSA SFM: Requirements and Guidance Dec 2002) 7.1 General The organization shall establish and maintain an SFM system, as described in Clause 7. SFM Policy The forest manager shall define a forest 7.2 SFM Policy management policy that includes a commitment The top management shall define and maintain to: the organization s SFM commitment through a systematic approach to forest policy statements and/or other documented public management appropriate to the nature, statements. The statement(s) shall contain a scale and impacts of the forest and commitment to forest activities; a) achieve and maintain SFM; continual improvement in management b) meet or exceed all relevant legislation, performance and forest management regulations, policies, and other requirements to outcomes to enhance the quality of the which the organization subscribes; environmental, economic, social, and c) respect Aboriginal and treaty rights; cultural values of forests and forest d) provide for public participation; resources; e) provide participation opportunities for compliance with relevant legislation and Aboriginal peoples with respect to their rights and other requirements to which the forest interests in SFM; manager subscribes; f) provide conditions and safeguards for the August 26, 2004 health and safety of DFA-related workers and 8

13 provision of resources appropriate to the nature, scale and impacts of the forest and forest activities; a process of regular review of forest management; and consideration of the views of stakeholders. System Requirements health and safety of DFA-related workers and the public; g) improve knowledge about the forest and SFM and to monitor advances in SFM science and technology and incorporate them where applicable; and h) demonstrate continual improvement in SFM. The statement(s) shall be documented, communicated, and made readily available. DFA and meeting the requirements of the Standard Note: While AS 4708 does not place the DFA information in the normative section of the standard, it is still explicitly addressed under AS 4708 s Introduction (Application of Requirements) as follows: defined forest area The forest manager will need to specify or define an area of forest (including land and water) to which the requirements of the AFS are applied. The defined forest area does not have to be a contiguous block or parcel of land. The forest manager will need to demonstrate management control over the defined forest area which allows them to affect achievement of the requirements of the AFS. The intent of the above guidance is to provide sufficient flexibility to allow forest managers to define the coverage of their AFS certificate in a way which reflects their business needs and differing operational situations. Nevertheless, it is intended that this guidance should preclude an organization omitting elements of its operation which should be properly included in its defined forest area from the scope of its certification Defined Forest Area (DFA) The organization shall designate a clearly defined forest area to which this Standard applies. The organization shall define the geographic extent and the respective ownership and management responsibilities for the DFA Shared Responsibilities General The organization shall ensure that all parties necessary to address the CSA SFM elements for the DFA are involved in the process. The organization shall clearly describe the respective roles and responsibilities of the parties involved. August 26,

14 System Requirements SFM Plan Legal Compliance The forest manager shall develop a forest management plan or equivalent instruments that: identifies applicable legal requirements and other external requirements to which the forest manager subscribes; identifies and assesses the significance of specific aspects and impacts of activities relevant to the full range of forest management performance requirements of the AFS; sets management objectives and targets and establishes a monitoring process for identified significant impacts relevant to the forest management performance requirements of the AFS; and respects stakeholder input provided under requirement The forest management plan or equivalent instruments should provide: scope and objectives of management; description of the forest estate and values to be managed, including those important for the protection of social benefits; rationale for the annual harvesting rates; description and rationale for silvicultural regimes; The forest manager shall define a forest management policy that includes a commitment to: compliance with relevant legislation and other requirements to which the forest manager subscribes; The forest manager shall ensure procedures are in place for: checking management plans and practices for compliance with legislation, codes of practice, regional and local prescriptions, guidelines and other relevant controls; The forest manager shall allow exercise of existing legal or traditional uses of the forests to continue. Where such uses threaten the integrity of the forest or the achievement of the forest management performance criteria, the forest manager shall pursue negotiated outcomes. The forest manager shall take appropriate action to constrain unauthorised or illegal activities. 7.3 Planning SFM Plan The organization shall document, maintain, and make publicly available an SFM plan for the DFA. The SFM plan for each DFA shall include a) a comprehensive description of the DFA; b) a summary of the most recent forest management plan and the management outcomes, including the conclusions drawn in the management review; c) a statement of values, objectives, indicators, and targets; d) current status and forecasts for each indicator, including a description of the assumptions and analytical methods used for forecasting; e) a description of the chosen strategy, including all significant actions to be undertaken and their associated implementation schedule; f) a description of the monitoring program; g) a comparative analysis of the actual and expected outcomes; and h) a demonstration of the links between shortterm operational plans and the SFM plan Rights and Regulations The organization shall a) demonstrate that relevant legislation and regulatory requirements that relate to ownership, tenures, and rights and responsibilities in the DFA have been identified and complied with; b) demonstrate that Aboriginal and treaty rights have been identified and respected; c) demonstrate that the legal and constitutional rights, and the health and safety of DFA-related workers, are respected and their contributions to SFM are encouraged; d) demonstrate that the acquired and legal rights of private woodlot owners to set their own values, objectives, indicators, and targets relating to their properties are respected; e) establish and maintain procedures to identify and have access to all legal and other requirements to which the organization subscribes that are applicable to the DFA. This includes requirements that relate to ownership tenures, rights, and responsibilities in the DFA. August 26,

15 System Requirements Implementation Responsibilities & Resources Operating Procedures Communication The forest manager shall ensure that: roles and responsibilities are defined and there is capacity to implement the system of management; The forest management plan or equivalent instruments should provide reference to relevant operating conditions and controls for specified activities The forest manager shall ensure that: operational plans, procedures, controls and guidelines are in place to achieve the forest management performance requirements; The forest manager shall ensure that: procedures for communication and documentation are established and maintained; 7.4 Implementation and Operation Structure and Responsibility Roles, responsibilities, and authorities required to implement and maintain conformance with the SFM requirements shall be defined, documented, and communicated within the organization. The organization shall provide resources essential to the implementation and control of the SFM requirements. Resources include human resources and specialized skills, technology, and financial resources. The organization shall appoint a specific management representative(s) who shall have defined roles, responsibilities, and authority for a) ensuring that the SFM requirements are established and maintained in accordance with this Standard; and b) reporting on the SFM requirements to top management for review and as a basis for continual improvement Operational Procedures and Control The organization shall a) identify the operational procedures and controls needed to meet the SFM requirements; b) establish and maintain documented procedures to cover situations where the absence of such procedures could lead to deviations from the SFM requirements; c) stipulate operating criteria, including maintenance and calibration requirements; d) communicate relevant procedures, controls, and requirements to suppliers and contractors; and e) ensure that contractors working on behalf of the organization have the necessary operational procedures and controls Communication General The organization shall a) establish and maintain procedures for internal communication between its various levels and functions; b) establish and maintain procedures for receiving, documenting, and responding to relevant communication from external interested parties; c) make the SFM plan publicly available; d) make an annual report on its performance in meeting and maintaining the SFM requirements publicly available; and August 26,

16 System Requirements e) make the results of independent certification and surveillance audit reports publicly available. Emergency Preparedness and Response Training & Awareness The forest manager shall ensure that: contingency / emergency plans are in place to respond to and manage accidents and emergency situations and that they include the prevention and mitigation of associated environmental impacts and are periodically tested The forest manager shall ensure that: staff and contractors have an adequate skills base and competencies to achieve the forest management objectives and targets; Emergency Preparedness and Response The organization shall a) establish and maintain procedures to identify the potential for and to respond to accidents and emergencies on the DFA; b) establish and maintain procedures to prevent and mitigate the impacts that may be associated with accidents and emergencies; c) review and revise, where necessary, its emergency preparedness and response procedures, in particular, after the occurrence of accidents or emergencies; and d) where practicable, periodically test procedures Training, Awareness, Qualifications, and Knowledge The organization shall identify training needs. It shall also ensure that personnel receive training related to the impact of their work upon the DFA and to their ability to ensure that the SFM requirements are met. The organization shall establish and maintain procedures to make its personnel at each relevant function and level aware of a) the importance of conformance with the SFM policy and with the SFM requirements; b) the environmental impacts, actual or potential, of their work and the benefits of achieving the SFM requirements; c) their roles and responsibilities in achieving conformance with the SFM policy and with the SFM requirements, including emergency preparedness and response requirements; d) the potential consequences of deviations from specified operating procedures. The organization shall ensure that its personnel are qualified on the basis of appropriate training and/or work experience and have opportunities to gain new knowledge. The organization shall also require contractors working on its behalf to demonstrate that their personnel have the requisite training and awareness levels. The organization shall improve knowledge about the DFA and SFM and shall monitor advances in SFM science and technology and incorporate them August 26,

17 System Requirements where and when applicable. Documentation The forest manager shall ensure that: procedures for communication and documentation are established and maintained; The review shall document any improvements to management performance and forest management outcomes SFM Documentation General The organization shall establish and maintain information, in paper or electronic form, to a) describe the SFM requirements and their interaction; and b) provide direction to related documentation. Organizations shall ensure that DFA-related workers and contractors have access to documentation relevant to their responsibilities and tasks Document Control The organization shall establish and maintain procedures for controlling all documents (paper or electronic) required by this Standard to ensure that a) they can be readily located; b) they are periodically reviewed, revised as necessary, and approved for adequacy by authorized personnel; c) the current versions of relevant documents are available at all locations where operations essential to the fulfillment of the SFM requirements and the SFM plan are performed; d) obsolete documents are promptly removed from all points of issue and use, or otherwise assured against unintended use; e) any obsolete documents retained for legal and/or knowledge preservation purposes are suitably identified. Documentation shall be legible, dated (with dates of revision), readily identifiable, maintained in an orderly manner, and retained for a specified period. Monitoring The forest manager shall monitor and evaluate forest management activities and their outcomes to ensure that forest management performance requirements are met and that deficiencies are corrected where identified to support continual improvement in forest management. The forest manager shall ensure procedures are in place for: monitoring and auditing of forest operations for conformance with Procedures and responsibilities for the creation and modification of the various types of documents shall be established and maintained. 7.5 Checking & Corrective Action Monitoring and Measurement General The organization shall a) establish and maintain documented procedures to monitor, on a regular basis, the key characteristics of its operations and activities that demonstrate progress towards SFM in the DFA. This shall include the recording of performance levels, relevant operational controls, and August 26,

18 System Requirements Corrective and Preventative Action (Internal) Auditing planned arrangements and to ensure that the forest management performance requirements are met; routine monitoring and evaluation of the outcomes of forest management using a systematic approach that allows remedial management actions or improvements to be applied at an early stage of detection to ensure that forest management performance requirements are met; Note: Refer also to AFS Clause below The forest manager shall ensure procedures are in place for: routine monitoring and evaluation of the outcomes of forest management using a systematic approach that allows remedial management actions or improvements to be applied at an early stage of detection to ensure that forest management performance requirements are met; The forest manager shall ensure procedures are in place for: periodically auditing the forest management system to determine whether or not it conforms to the planned arrangements and has been properly implemented and maintained. conformance with the SFM requirements; b) monitor the indicators for comparison against the forecasts; and c) establish and maintain a documented procedure for periodically evaluating compliance with relevant legislation and regulations, and conformance with relevant policies applying to the DFA. If noncompliances or nonconformances are found, the organization shall address these through the corrective and preventive action process Corrective and Preventive Action The organization shall establish and maintain procedures for a) defining responsibility and authority for identifying and investigating nonconformance; b) taking action to mitigate any impacts caused; and c) initiating and completing corrective and preventive action. Any corrective or preventive action taken to eliminate the causes of actual and potential Non-conformances shall be appropriate to the magnitude of problem and commensurate with the impact encountered Internal Audits to the SFM Requirements The organization shall a) establish and maintain procedures for annual internal audits to ensure that it conforms to the SFM requirements set out in this Standard; and b) provide information on the results of these internal audits to top management. The organization s internal audit program, including any schedules, shall be based on the importance of the specific SFM activity and the results of previous audits. To be comprehensive, the audit procedures shall cover the audit scope, frequency, and methods, as well as the responsibilities and requirements for conducting audits, auditor qualifications, and reporting results. August 26,

19 System Requirements Management Review Ownership Rights Incorporation of Public Participation Requirements Setting DFA Performance Requirements The forest manager shall periodically review and where necessary modify the forest management system and its procedures to ensure its continuing suitability, adequacy and effectiveness and to ensure continual improvement in management performance and forest management outcomes are achieved. The review shall cover: the results of auditing and monitoring of forest operations and activities, and other relevant information; monitoring and feedback mechanisms, including the adequacy of monitoring activities; and policy, objective and targets, and changes to other elements of the management system to meet changing circumstances, new information and the commitment to continual improvement. The review shall document any improvements to management performance and forest management outcomes. Note: The AFS does have specific public participation requirements, it simply does not explicitly call for them to be incorporated into the SFM system. Note: The AFS tends to have more specific requirements in many of the criteria it requires, whereas the CSA utilizes the public participation process to develop specific objectives, indicators and targets for the CSA SFM elements, which in turn are based on the CCFM criteria. 7.6 Management Review The organization s top management shall, at least annually, review the SFM requirements to ensure that progress towards SFM continues to be suitable, adequate, and effective. The management review process shall ensure that the information necessary to allow top management to carry out this evaluation is collected. This review shall be documented. In order to be adaptive, the management review shall address the possible need for changes to policy, targets, and other SFM requirements, in light of audit results, changing circumstances, and the commitment to continual improvement. Note: Refer also to row above, CSA b) Ownership Rights and Responsibilities The organization shall respect the legal rights and responsibilities of other parties in the DFA that are not part of the registration applicant Incorporation of Public Participation Requirements The public participation requirements set out in Clause 5 of this Standard shall be incorporated into the SFM system Setting DFA -Specific Performance Requirements General The organization, working with interested parties in the public participation process at each stage, shall establish DFA-specific performance requirements that address all the CSA SFM elements in Clause 6. The work shall be recorded in the SFM plan and shall be summarized in accordance with the example in Annex C. For each element, one or more DFA-specific values shall be identified. For each value, one or more objectives shall be set. For each value, one or more indicators shall be identified. Indicators shall be quantitative where feasible. For each indicator, data on the current status shall be provided, and one target shall be set. August 26,

20 System Requirements Records Note: The AFS does not have an explicit requirement around record keeping. Each target shall specify acceptable levels of variance for the indicator and clear time frames for achievement. Alternative strategies shall be identified and elaborated. Forecasts shall be prepared for the expected responses of each indicator to each alternative strategy. Assumptions and analytical methods used for making each forecast shall be described. During plan implementation, measurements shall be taken for each indicator at appropriate times and places. Measurement results shall be interpreted in the context of the forecasts in the SFM plan. See Clauses and 7.6 for the continuation of the adaptive management process Records The organization shall establish and maintain procedures for the identification, maintenance, and disposition of SFM requirement records. These records shall include training records and the results of audits and reviews. SFM requirement records shall be legible, identifiable, and traceable to the activity involved. SFM requirement records shall be stored and maintained in such a way that they are readily retrievable and protected against damage, deterioration, or loss. Their retention times shall be established and recorded. Records shall be maintained, in a manner appropriate to the system and to the organization, to demonstrate conformance to the requirements of this Standard. August 26,

21 Participation Requirements 4. Public Participation Requirements Similarities Both the AFS and CSA standards are similar in that they offer meaningful opportunities for public participation in the development of the forest management plan. Both the AFS and CSA standards require that the applicant: Provide for public participation Contact relevant stakeholders (AFS) / a broad range of interested parties (CSA) affected by or with an interest in the management of the defined forest area. Facilitate meaningful participation in the development of the SFM plan Demonstrate how views/inputs were considered Make a summary of the plan available to stakeholders (AFS) / make the plan publicly available (CSA) Differences The comparative analysis in the matrix below of the public participation requirements provides evidence of meaningful public participation opportunities in both the AFS and CSA standards. However, the AFS and CSA differ in that the CSA relies on the establishment of an on-gong public participation process to identify and select values, objectives, indicators and targets for each of the CSA SFM elements, as well as any other elements of relevance to the defined forest area, whereas, the AFS provides more specificity at the outset through its forty requirements within its nine SFM criteria. With the CSA Standard, the influence of local interests does not conclude with the adoption of the SFM plan requirements, but is sustained by those interests collaborative participation in an on-going process: To review the SFM plan Design monitoring programs, evaluate results, and recommend improvements; and Discuss and resolve any issues relevant to SFM on the DFA. Given the comprehensive scope of the CSA s public participation process, the CSA Standards also requires that participants agree to the public participation operating rules, and insists that the basic operating rules include provisions for a wide variety of process elements as per CSA It is the CSA SFM TC s opinion that the public participation requirement of the CSA Standard is one of the most rigorous of its kind in certification standards in the world today. Because Canadian forests are primarily publicly owned, it is vital that a Canadian forest certification standard involve the public extensively in the forest management planning process. Forest management that meets the SFM requirements of the CSA Standard involves a positive relationship between the organization and the local community. (Source: Introduction to CAN/CSA Z809-02). It is worth noting that the AFS differs from the CSA in that it has explicit considerations around good neighbour relations as per AFS Clause in the matrix below. For example, AFS requires consideration of the impact of forest operations on neighbours and to take appropriate actions to minimize adverse impacts. AFS also requires that neighbours directly affected and responsible authorities be notified before commencing forest operations. August 26,

22 Participation Requirements AFS and CSA Comparative Matrix of Public Participation Requirements Points of Comparison: Participation High Level Public Participation Requirements Contacting Stakeholders / Interested Parties AS 4708 (AFS) Section 4.2, incl. Criterion 2 on Public Participation 4.2 Criterion 2 Forest management shall provide for public participation and foster on-going relationships to be a good neighbour The forest manager shall identify and establish contact with relevant stakeholders, including groups and individuals, directly affected by or with an interest in management of the defined forest area. Note: Refer also to AFS which provides for the recognition of Indigenous rights, significant indigenous input into decisionmaking as well as the application of Indigenous peoples knowledge of sustainable development and management of forests on the defined forest area (and more). CAN/CSA Z (CSA) Section 5. Public Participation Requirements 5. Public Participation Requirements 5.1 Basic Requirements The organization shall establish and implement a public participation process by either starting a new process; building on an existing process; or reviving a previous process. 5.2 Interested Parties The organization shall a) openly seek representation from a broad range of interested parties, including DFA-related workers, and invite them to participate in developing the public participation process; b) provide interested parties with relevant background information; c) demonstrate through documentation that efforts were made to contact Aboriginal forest users and communities affected by or interested in forest management in the DFA; d) demonstrate through documentation that efforts were made to encourage Aboriginal forest users and communities to become involved in identifying and addressing SFM values; e) recognize Aboriginal and treaty rights and agree that Aboriginal participation in the public participation process will not prejudice those rights; f) establish and maintain a list of interested parties, including those that chose to participate, those that decided not to participate, and those that were unable to participate. The list shall contain names and contact information, as well as any links to the organization. August 26,